The need for the inclusion of all minerals in EU regulation for conflict due diligence

Through the use of minerals in their products, companies risk contributing to conflict financing or human rights abuses in their mineral supply chains, especially if upstream operations are situated in conflict zones. This problem is being addressed by the European Commission, that is taking steps to break the link between mineral trade by EU companies and conflict. The Commission has proposed a new regulation with a due diligence framework to address the risk of financing armed groups and security forces, and mitigate other adverse impacts that are associated with the extraction, transport and trade of four different minerals. This briefing paper discusses one specific issue in the proposed regulation: the limited number of conflict minerals included in the proposed EU regulation. This paper argues that the decision to focus on the import of minerals and metals containing or consisting of tin, tantalum, tungsten and gold (3TG) is arbitrary and far too limited to achieve the proposal’s objective of reducing the financing of armed groups and security forces through minerals proceeded in conflict-affected and high-risk areas.

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